As mentioned at the MassDEP Waste Site Cleanup Advisory Committee meeting last month, there will be a meeting on Wednesday, November 16, 2016 to discuss possible revisions to the Massachusetts Contingency Plan provisions concerning Imminent Hazards.

The meeting will be begin at 9:30 am and will be located in Conference Room C on the 2nd floor of MassDEP’s 1 Winter Street, Boston office.  (The duration of the meeting will depend upon the depth and breadth of the discussion. The room is reserved until 12:00 pm.) Please click here for directions.  

The discussion will focus on the identification and response to conditions currently considered Imminent Hazards (IH):

  •         The statutory and regulatory definitions of Imminent Hazard, Substantial Hazard and Significant Risk;
  •         How the “short period of time” inherent in Imminent Hazards is reflected in the calculations;
  •         Potentially limiting Imminent Hazard evaluations to short exposure periods (e.g., less than 6 months or something appropriately “short”);
  •         Possible re-classification of (current) Imminent Hazards based on 5-year exposures to Substantial Hazards;
  •         The timeliness of notifications for Imminent and Substantial Hazards (current and potential future definitions);
  •         The nature of the required response actions for Imminent and Substantial Hazards (current and potential future definitions);
  •         Other statutory and regulatory implications of a potential reclassification of SOME Imminent Hazards to Substantial Hazards, such as (but not limited to)
    •    The list of conditions that could pose an Imminent Hazard (310 CMR 40.0321);
    •    DEP’s statutory obligation to address Imminent Hazards ;
    •    The limitation on using AEPMMs for conditions posing an Imminent Hazard for less than 60-day exposures;
    •    LSP’s obligation to notify for Imminent Hazards

Stakeholders are welcome to forward additional discussion items related to this Imminent Hazard topic before the 11/16 meeting to make sure the topics are on the agenda.  If you have any questions (or items), please feel free to send them to  We look forward to seeing you on the 16th.

Related links:
Massachusetts Contingency Plan (MCP, 310 CMR 40)  
Waste Site Cleanup Advisory Committee page
March 2016 list of DRAFT potential MCP amendments